OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

June 16, 1988

Diane H. Hays, R.N.
Occupational Health Nurse
Davis Memorial Goodwill Industries
2200 South Dakota Avenue, N.E.
Washington, D.C. 20018

Dear Ms. Hays:

This is in response to your letter of April 27 requesting information on the training requirements of your employees as required by the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).

The employer has the responsibility to train employees regarding protective practices implemented in their workplace and to explain the labeling system used and how to obtain and use material safety data sheets. Training is crucial to the comprehensive hazard communication program as training explains and reinforces the information presented to employees through the written mediums of labels and material safety data sheets. While the HCS provisions are performance-oriented, the minimum information in 29 CFR 1910.1200(h) must be presented to assure effective employee training concerning the hazards of the particular job assignment.

In view of the above requirements, as a minimum, generic training should be given to all your employees prior to job assignments where they will be or potentially could be exposed to hazardous chemicals. Since your employees are contracted to extended job assignments, directly working under the supervision of the other employer, you can possibly work out a contractual agreement for the other employer to provide the training specific to the hazardous materials used at that job site. It is our recommendation that you actively assure yourself that such training is being provided and is adequate to fulfill your employer responsibilities under the HCS. For your employees, the training program will most likely be the most important component of your hazard communication program because it can be individualized to your employees' abilities. Every effort must be made to train and effectively warn the employees of exposure to hazardous chemicals at the appropriate level of their understanding in view of their special educational requirements.

If we can be of further assistance, please feel free to contact us.


Thomas J. Shepich, Director
Directorate of Compliance Programs